Privacy Policy

1Purpose

Innovative Solutions Group (“Innovative Trials” or “We”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or contact us via email or phone and share your data with us. It also tells you about your privacy rights and how the law protects you. Additionally, this policy applies to any portals created by Innovative Trials on behalf of its clients, ensuring the protection of personal data shared through these platforms. We may monitor use of these portals to ensure compliance with our IT-related policies and for other business reasons, as permitted or required by law.

1.1Important information about us

1.1.1Purpose of this privacy policy

This privacy policy aims to give you information on how Innovative Trials collects and processes your personal data through your use of this website, including any data you may provide through this website when you complete any forms on our site or send any information to us, as well as any data that you provide to us in person, via email, or on the phone. It is important that you read this privacy policy so that you are fully aware of how and why we are using your data.

Innovative Trials does not knowingly collect or use personal data relating to children, except when specifically required for contracted research studies and clinical trials. In such cases, the collection and use of personal data will be conducted in strict compliance with applicable data protection laws, including the UK GDPR and the Data Protection Act 2018. Section 2.3 below outlines the specific measures and safeguards implemented to ensure the protection of children's personal data during these research studies.

We may act as both the controller and processor of your personal data, depending on the client and situation. In situations where we act as a processor, we will process personal data in accordance with the instructions of the relevant controller. If you have any questions regarding this policy, including any requests to exercise your legal rights, please contact our Data Protection Officer using the details set out below:

Full name of legal entity

Innovative Solutions Group

Email address

Privacy@innovativetrials.co.uk

Postal address

Innovative House, Avenue One, Letchworth Garden City, SG6 2WW

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

1.1.2Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in July 2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.1.3Third-party links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2Scope

2.1The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username, or similar identifier, including your image and your voice.
• Contact Data includes billing address, delivery address, email address and telephone numbers, and emergency contact information.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• Survey Data includes your responses to our online and offline surveys.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.

2.2Special category data

When we are contracted by our clients to support the recruitment and retention of participants for clinical research studies, we may ask you to provide:

• information about your health and/or
• genetic and biometric data

The information requested will be aligned with the therapeutic area and the inclusion and exclusion criteria of the specific study.

We will require this information to conduct the following:

Patient Pre-screening purposesif you register your interest in a clinical study we were hired to support. We may contact you to ask more questions related to your health to assess if you meet the inclusion criteria of the study you are interested in. Depending on your answers, we may then pass your details to the study site you selected. The site personnel will contact you again to finalise the screening process with you. After this point, we will hold your personally identifiable information in our secure database for the duration of our support of the study, which will be specified in the contract between us and our client (study sponsor or their representative). Your data will be permanently deleted afterwards.

Sometimes it may be identified that you do not fully meet the study inclusion criteria. In these cases, we will hold your data in our secure database until our support on the study finishes. We may contact you in the future if the study inclusion criteria change to check if you are still interested in joining the study. In some cases, you may be eligible to join a study, but their study site near you/ selected by you is not open for patients yet. Your data will be permanently deleted afterwards.

Patient Retention servicesif you join the study we were hired to support, we may contact you on a regular basis to check if there is anything you need from the study team. We may ask how you are, if you have any problems with the study participation and other questions as agreed by the client. This service will be described in depth in the Informed Consent Form that you signed to confirm your participation in the study. Your data will be stored in our secure database for the duration of our support of the study and then anonymised and moved to an electronic archive to be stored for 25 years. After that, it would be permanently deleted.

Study website serviceswe offer study specific websites which have a form where you can register your interest in participation in the study. The form will ask for your name and telephone number (or email address). You may also be asked to identify the study site that is closest to you. The data you provided in the contact form will be recorded in a secure portal that is attached to the website. It will then be accessed by the personnel who has been appointed to contact you to discuss the study. The information on how the specific study websites work and which country your data is stored in will be included in the Website policy available on each study website. As you interact with the website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Post-Study support servicessometimes, study sponsors offer further support to participants after the study has ended. The sponsor may hire us to help them deliver this service. If you are eligible for further support, you may contact us to request it. As a result, we will have your name and contact details (email address and/ or telephone number and some health information related to the study and support required. We will keep your details for the duration of our contract with the sponsor for reporting purposes. The service is voluntary and we will ask for your consent to share the data with us.

Apart from the above, we do not generally seek to collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership). Nor do we usually collect any information about criminal convictions and offences.

If we seek to collect any other Special Categories of Personal Data, we will do so in accordance with applicable law. As we collect the data in relation to a clinical study, the data we request and the questions we ask are approved by the Ethics Committee/ Institutional Review Board in your country.

Unless we have specifically requested such data, however, we ask that you do not send us, nor share with us, any Special Categories of Personal Data.

2.3Processing of personal data relating to children

Innovative Trials shall ensure that the processing of personal data relating to children involved in pharmaceutical trials is conducted in compliance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (DPA 2018), and the ICO Children's Code, as well as applicable ethical standards. We shall obtain explicit consent from the child's parent or legal guardian prior to processing any personal data. We shall implement appropriate technical and organisational measures to protect the personal data of children, ensuring that such data is processed lawfully, fairly, and transparently. We shall provide a privacy notice to the parent or legal guardian, detailing the purposes of processing, the lawful basis for processing, and the rights of the data subject. We shall ensure that any third parties involved in the processing of children's personal data are subject to contractual obligations that ensure compliance with relevant data protection laws and the ICO Children's Code.

As we collect the personal data in relation to a clinical study, the data we request and the questions we ask are approved by the Ethics Committee/ Institutional Review Board in your country.

2.4If you fail to provide personal data

You are not obliged to provide your data to us. However, if you interact with us in a professional or business capacity, where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you, for example, to provide you with services. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time. If you fail to provide the necessary data, we may also be unable to comply with our legal obligations, which could result in the termination of our business relationship.

If you interact with us as an individual interested in a study we support, and do not provide your personal data to us, you may not be able to participate in our services, and we may not be able to respond to your queries.

3Abbreviations and acronyms

Consent

means you freely provide a specific, informed, and unambiguous indication of your wishes through a written statement or clear affirmative action, inter alia, to being contacted by our marketing teams, or being asked to participate in a market research project which would be collected on our behalf by us or our third-party recruiters.

Legitimate Interest

means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract

means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation

means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Ethics Committee or Institutional Review Board

means a committee that reviews and approves research studies involving human participants to ensure their safety and ethical treatment. Depending on the country, they are called Ethics Committees or Institutional Review Boards (IRB).

4Regulatory requirements

Innovative Trials shall ensure compliance with all applicable data protection laws and regulations, including but not limited to the UK Data Protection Act 2018, the UK Privacy and Electronic Communications Regulations 2003, and relevant international data protection laws, throughout the duration of its pharmaceutical trials. Innovative Trials shall implement appropriate technical and organisational measures to protect personal data against unauthorised or unlawful processing and against accidental loss, destruction, or damage.

A. Compliance with UK data protection laws

Innovative Trials shall comply with the UK Data Protection Act 2018 and the UK Privacy and Electronic Communications Regulations 2003, ensuring that all personal data processed in the UK is handled in accordance with these laws.

B. Compliance with international data protection laws

Innovative Trials shall comply with relevant international data protection laws applicable to its operations, ensuring that personal data processed outside the UK is handled in accordance with those laws. This includes the Regulation (EU) 2016/679 (General Data Protection Regulation).

C. Conflict of laws

In the event of a conflict between the data protection laws of the UK and another jurisdiction, Innovative Trials shall apply the stricter requirements to ensure the highest level of protection for personal data.

D. Registration and fees

Innovative Trials shall maintain valid registrations and pay any required fees to the Information Commissioner or relevant supervisory authorities, unless an exemption applies.

5Policy details

5.1How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you give to:
  • Provide and maintain our services to you.
  • Conduct our services and complete our client contracts.
  • Notify you about changes to our services.
  • Provide client support.
  • Gather analysis or valuable information so that we can improve our services.
  • Monitor the usage of our services.
  • Detect, prevent, and address technical issues.
  • Provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
• Direct interactions when collecting health information and genetic and biometric data. You may give us your name, contact details such as telephone number and email address. Any health information requests will be dictated by our clients as required for participation in a specific study. The data we collect and the questions we ask will be approved by the relevant Ethics Committee/ Institutional Review Board that gives approvals to run clinical research studies. This includes personal and health data you give to:
  • Contact you to discuss your or your dependant's (child or other) participation in the study you expressed interest in.
  • Ask your health-related questions to evaluate if your or your dependant’s health profile matches the study criteria.
  • Once accepted on the study, contact you on a regular basis as established in the Informed Consent Form to provide support and check on your wellbeing.
  • Provide a point of contact if you need support with your study participation or have a study related question.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy available on our website for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Identity Data, Contact Data, and Technical Data from our software providers.
  • Identity Data and Contact Data from publicly available sources such as the Electoral Register and Companies House.
  • Contact Data, Financial Data, and Transaction Data from providers of technical, payment, and delivery services.

5.2How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• When our clients have provided third party personal data so we can conduct our work on their behalf.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, in these scenarios, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. See section 5.4 Marketing for further details.

We will also use your personal data if you contact us in regards to a research study that we were hired to support:

• When you provided consent to contact you to discuss your participation in a clinical study you expressed interest in (either for yourself or your child).
• Once you are qualified as a participant of a clinical study, when you provide consent to be contacted to receive our support during your journey on the study.

We do not send our company’s marketing materials to patients or prospective patients. If we were to send such communications, we would obtain your consent in advance. You have the right to withdraw consent to marketing at any time by contacting us. See section 5.4 Marketing for further details.

5.3Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data, where more than one ground has been set out in the table below:

5.4Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you are an individual interested in a clinical study or a participant of a study we support, we will not use your data to contact you for any marketing purposes, unless you specifically requested our representative to do so.

5.4.1Promotional offers from us to business contacts

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

5.4.2Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

5.4.3Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

5.5Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.6Disclosure of your personal data

We may employ third party companies and individuals to facilitate our service, provide service on our behalf, perform service-related services, or assist us in analysing how our service is used.

We may share your personal data with third parties for the purposes set out in the table Purposes for which we will use your personal data above. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5.7International transfers

Some of our external third parties and clients are based outside the UK, which may involve transferring your personal data internationally. Whenever we transfer your personal data out of the UK, we ensure it receives a similar level of protection by implementing one of the following safeguards:

• We will only transfer your personal data to countries that have been approved by the Information Commissioner's Office (ICO) as providing an adequate level of protection for personal data. This includes the European Economic Area (EEA), and other countries deemed adequate by the European Commission.
• For data transfers from the EEA to the UK, the European Commission has determined that the UK provides an adequate level of protection.
• Where we use certain service providers, we may implement specific contracts approved by the ICO, known as Standard Contractual Clauses, to ensure your personal data receives the same protection as it does in the UK.
• If you are located in a country outside of the UK and EEA, we will ensure that the transfer of your data to the UK or EEA is completed in compliance with the local law.

5.8EU data protection representative

As Innovative Trials processes the personal data of individuals of the European Union and European Economic Area, in our role as either “Data Controller” or “Data Processor”, we have appointed DataRep as our Data Protection Representative for the purposes of the EU General Data Protection Regulation in the EU/EEA.

If Innovative Trials has processed or is processing your personal data, you may be entitled to exercise your rights under GDPR in respect of that personal data. For more details on the rights you have in respect of your personal data, please refer to the European Commission or the National Data Protection Authority in your country.

Innovative Trials takes data protection of personal data seriously and has appointed DataRep as their Data Protection Representative in the European Union so that you can contact them directly in your home country. DataRep has locations in each of the EU countries and Norway and Iceland in the European Economic Area (EEA), so that Innovative Trials’s customers can always raise the questions they want with them.

If you want to raise a question to Innovative Trials or otherwise exercise your rights in respect of your personal data, you may do so by:

• Sending an email to DataRep at datarequest@datarep.com quoting Innovative Trials in the subject line,
• Contacting us on our online webform at www.datarep.com/data-request or
• Mailing your inquiry to DataRep. Please see the addresses in the Appendix at the end of this Policy.

PLEASE NOTE: when mailing inquiries, it is ESSENTIAL you mark your letters for “DataRep” and not Innovative Trials or your inquiry may not reach us. Please refer clearly to Innovative Trials in your correspondence. On receiving your correspondence, Innovative Trials will request evidence of your identity to ensure your personal data and information connected with it is not provided to anyone other than you.

If you have any concerns about how DataRep will handle your personal data, please refer to their privacy policy.

5.9EU legal representative under the Digital Services Act (Regulation EU 2022/2065)

Innovative Trials, which delivers or targets the delivery of digital services in the European Union and European Economic Area, has appointed DataRep as its Legal representative for the purposes of the Digital Services Act in the EU/ EEA.

Innovative Trials takes their obligations to deliver a safe and legal service seriously and has appointed DataRep as their legal Representative in the European Union so that you can contact them directly about concerns you may have, regarding our websites or other digital services, and to report illegal content which you identify.

If you want to raise a question to Innovative Trials regarding these issues, you may do so by:

• Sending an email to DataRep at digitalrequest@datarep.com quoting Innovative Trials in the subject line,
• Contacting us on our online webform at www.datarep.com/data-request,
• Mailing your inquiry to DataRep at DataRep, the Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland, or
• Calling DataRep on +353 (1) 919 8899. We will ask you to follow up by email to ensure our understanding of your request.

PLEASE NOTE: when mailing inquiries, it is ESSENTIAL you mark your letters for “DataRep” and not Innovative Trials or your inquiry may not reach us. Please refer clearly to Innovative Trials in your correspondence.

If you have any concerns about how DataRep will handle your personal data, please refer to their privacy policy.

5.10Data security

Unfortunately, the transmission of information via the internet is not completely secure. Although we will take reasonable steps to protect your personal data, such as data anonymisation and encryption (at rest and in transit), we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We request that our third-party contractors and site service providers follow similar standards of security and confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

5.11Data retention

5.11.1How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements such as our contracts with our clients.

In some circumstances, you can ask us to delete your data: see your legal rights below for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

5.11.2No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

5.11.3What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

5.11.4Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

5.12Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request accessto your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correctionof the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasureof your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processingof your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processingof your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transferof your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consentat any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

5.13Use of artificial intelligence (AI) technology

Certain services offered by Innovative Trials incorporate Artificial Intelligence (“AI Technology”) to enhance and optimise our operations, provide personalised services, generate insights, and improve user experiences. These technologies are designed to assist with the data processing activities described in this Privacy Policy, ensuring that our services are efficient, reliable, and tailored to meet user needs. We are committed to using AI responsibly and ethically. To this end, we implement reasonable and appropriate controls to manage the use of AI Technology, including rigorous validation procedures to mitigate and prevent inappropriate bias in AI outputs. These measures ensure that the results generated by AI are fair, accurate, and aligned with the purposes for which they are intended.

Safeguards for AI use and your rights

Your personal data will only be processed using AI Technology in ways that are lawful, transparent, and consistent with the purposes outlined in this Privacy Policy. To protect your rights, we apply the following safeguards when using AI Technology:

• Human oversight: AI-driven processes that could result in decisions with legal or similarly significant effects are subject to meaningful human oversight to ensure fairness, accuracy, and accountability.
• Bias prevention: We continuously assess and address potential biases in AI algorithms and models to ensure that outputs are equitable and inclusive.
• Data protection: All data processed using AI is handled securely and in compliance with applicable data protection laws.
• Transparency: We strive to provide clear information about how AI Technology is used, the purposes of its use, and the potential impacts on you.

Limitations of AI use

We do not use AI Technology to make decisions that have a significant legal effect on you without your explicit consent or appropriate safeguards, such as ensuring human review. Additionally, AI Technology is not used for profiling that would infringe upon your rights or freedoms under applicable privacy laws.

Definition of AI Technology

For the purposes of this Privacy Policy, “AI Technology” refers to any products, services, features, or tools that utilise machine learning software, algorithms, hardware, or other artificial intelligence capabilities to:

• Generate content (e.g., text, images, or other media);
• Analyse and interpret data;
• Make predictions or recommendations; or
• Automate decisions or processes.

6Appendix 1

DataRep offices in the EU/EEA

When preparing your own documentation identifying DataRep to be contacted as your Data Protection Representative, please ensure those contacting are instructed to post their requests addressed to ‘DataRep’ and not your organisations directly; communications addressed to you directly but at our contact locations will likely not be received.